The BSA (31 CFR Chapter X) requires each financial institution to implement an AML/CFT program. The AML/CFT program must include written policies and procedures designed to prevent the business from being used for money laundering or terrorist financing activities. In addition, the written program must designate an AML/CFT compliance person, and it must include provisions for the training of personnel and the independent testing of the program. To ensure a risk-based and reasonably designed program, a financial institution must assess its money laundering and terrorist financing (ML/TF) risks.
SIRS’ comprehensive AML/CFT compliance services meet these requirements. SIRS conducts the risk assessment, prepares the written policy, performs the independent test, and provides online training for personnel.
As shown on our industries page, SIRS uses a transparent and flat-rate pricing model. Each business category (investment adviser, mortgage broker or lender, securities broker/dealer, and precious metals & jewelry dealer) falls within a fixed price range for comprehensive AML/CFT services. After reviewing the business size and other factors, SIRS provides a service agreement with a flat-rate price.
The AML Act of 2020 requires each financial institution to implement a risk assessment process. This process must “identify, evaluate, and document” the money laundering and terrorist financing risks that the business faces. As part of this process, a financial institution must periodically evaluate its business activities, including products, services, channels, customers, intermediaries, and geographic locations.
To address this requirement, SIRS will design the risk assessment process and prepare a written assessment of the client’s ML/TF risks. The assessment will incorporate guidance from FinCEN, FATF, the US Treasury Department and other reliable sources. The completed risk assessment will serve as the basis for the client’s AML/CFT compliance program.
Based on the client’s business activities and relevant BSA criteria, SIRS will prepare a customized AML/CFT program or “policy”. The written policy will reference, and include links to, industry-specific regulations found in 31 CFR Chapter X.
SIRS will design the AML/CFT program to be risk-based and practical. It will feature an index and easy-to-understand text, serving as a useful resource and reference manual for the client. With clear and concise policies and procedures, SIRS keeps AML/CFT programs shorter than those based on generic templates. Depending on the industry, these programs typically range from 15 to 20 pages.
Training is one of the main pillars of a financial institution’s AML/CFT program. As a best practice, a regulated business should ensure that its personnel complete an AML/CFT training course each year.
SIRS offers online AML/CFT training courses for RIAs, RMLOs, and precious metals and jewelry dealers. Each of these sector-specific courses addresses the risks and regulatory requirements applicable to the sector. Participants can complete the training in 12-14 minutes. After passing the course and quiz, they receive a completion certificate.
SIRS’ independent AML/CFT testing service includes a comprehensive review of the client’s AML/CFT program. The test (also known as an “audit”) takes a two-pronged approach: 1) reviewing the client’s written AML/CFT policies and procedures to ensure they address relevant, industry-specific, BSA criteria, and 2) examining the AML/CFT records the client maintains to demonstrate compliance with the Firm’s written procedures.
After completing the test, SIRS will provide a written report that details its findings and, if needed, recommends improvements. Throughout the testing process, SIRS will collaborate with the client as a partner. When identifying gaps in the AML/CFT program, we will work with you to resolve or mitigate those issues whenever possible. This collaborative approach helps ensure the final report presents the client more favorably.